We explain below how we use and protect the personal information we may gather from and about our customers by means of our websites, mobile applications, online booking widgets (i.e. online booking applications run by our third-party partners such as hotel providers, airlines, etc), our corporate, rental, and sales locations, and from third-party sources. By using our websites or mobile applications, you consent to the collection, use, and disclosure of your information, as described in this Privacy Policy.

The nature of the business and operations require us to share your reservation and booking information with our franchisees or licensees, (“Licensees”). For these transactions, the Licensee is an independent data controller or equivalent under applicable law and may maintain its own privacy policy in respect of the rental data that you provide to the Licensee. You are encouraged to check the privacy policy of the Licensee that is applicable to your transaction.

To identify who is the data controller or equivalent under applicable law in respect of your personal data, please see Data Controllers and Contact Information by Country.

The Types of Information We Collect
How We Use This Information
How Your Information May Be Shared
Data Security and Integrity
Global Data Transfers and Processing
Changes to this Policy
Contacting Us
Use of Cookies and Similar Technologies

The Types of Information We CollectInformation Collected About You
You may provide us with certain information in connection with a transaction or in your interactions with our websites and at our locations. When you are asked to provide personal information, you may decline. If you choose not to provide the information, you may not be able to use some products or services. The personal information we may collect includes:

Your name, contact information, date of birth, driver’s license number and expiration date and emergency contact information;
Vehicle rental information, including the location of where the vehicle is rented, date of rentals, type of rental, and your preferences;
Your credit card details, Enterprise, Alamo, or National rewards information, online user account details, membership/corporate ID numbers, passport information, and frequent flyer or travel partner affiliations;
Information you provide regarding your marketing preferences or in the course of participating in surveys or promotional offers;
Photographs you submit of you and your driver’s license or your receipts through camera features available on some of our mobile applications and websites;
Financial information that may be necessary to facilitate the purchase or lease of a vehicle from a Car Sales or Fleet Management location;. (Additional notices will be provided to you at the time of that transaction.)
Additional contact information about you that we may obtain through third parties with whom we do business (e.g. travel agents, Car Sales lead providers or similar providers).
With your consent, we may access location-based information or collect location markers from your mobile device or based on your IP address. We may use this information to provide you with notifications related to our locations, return information, local offers or other information that may be helpful in providing you better services. We do not use this information to specifically locate you for any reason other than to provide you the service. With your consent, our application may utilize your device’s camera. If you have allowed us to utilize your location information or your device’s camera in the past and wish to revoke the permissions, please change the settings at the device level.

If permitted by law, in certain areas of our sites, we provide you the ability to enter your friend’s name and contact information in order for us to send your friend a one-time email inviting him or her to visit the sites. We also provide you the ability to enter a friend’s or other individual’s name and contact information in order to make bookings for that friend or other individual. You must have obtained the consent of your friends before making such submissions. The information you provide will not be used for any further marketing purpose unless your friend requests services or we otherwise obtain consent from that person. Please be aware that when you use any send-to-a-friend functionality on our sites, your name and e-mail address may be included in the communication sent to your friend.

Information Collected and Stored Automatically
By visiting our websites, certain information may be automatically provided to us by your computer. For each visitor to our websites, our webservers automatically recognize the visitor’s domain name or IP address. An IP address is a number assigned to your computer when you connect to the Internet. As part of the protocol of the Internet, webservers can identify your computer by its IP address. In addition, we may collect your browser type and operating system as well as your internet service provider (ISP), referring and exit pages, date and time stamp, and/or clickstream data. We collect similar information when visiting our websites with your mobile device, including mobile device brand, model, mobile operation system and carrier. Except as otherwise explained in this policy, we may combine the non-personal information we collect from you (as described above and as described below, under “Use of Cookies and Similar Technologies”) with your personal information in order to tailor our websites and enhance your online experience by saving your preferences and/or to help identify site features, advertisements and offers that may be of interest to you.

Use of Cookies and Similar Technologies
Asia CiTy Tours and our partners use cookies, pixel tags, etags, HTML 5 storage and similar technologies on most of our sites and in promotional emails which we may send to you. To learn more about our practices, please see our Cookie Policy.

Vehicle Operation and Location Data
Our vehicles may be equipped with the manufacturer-provided or another vehicle telematics system (“Telematics System”). Some or all Telematics System functionality may or may not be active during rental periods. Telematics Systems may provide us use of, disclosure of, or access to (1) location information, (2) crash notification and related crash data and, (3) operational condition, mileage, diagnostic and performance reporting of vehicles (“Telematics Data”), as permitted by law.

Use of the Telematics System is subject to the terms and conditions and privacy policy posted by the applicable Telematics Systems provider and/or vehicle manufacturer (in the case of OnStar, information is available at www.onstar.com), which may include system and service limitations, warranty exclusions, limitations of liability, wireless service provider terms, privacy practices, descriptions of use and sharing of information, and user responsibilities.

If you choose to use the Telematics System, we are not responsible for any data that is left in the vehicle as a result of your use. We cannot guarantee the privacy or confidentiality of such information, and you must wipe it before you return the vehicle to us.

Children’s Privacy
Our websites and online marketing are not directed to, and Asia CiTy Tours does not knowingly collect personal information from, children under the age of 18 or your country’s age of minority. If you nevertheless believe that your child has provided us with their personal information and you need to let us know to delete it, please email us at privacy@asiacitytours.com (US and Canada) or your country’s email address found in the Data Controllers and Contact Information By Country section below.

How We Use This Information
We use the information we collect for the following purposes:

To assist the transactions that you request, such as reserving and renting motor vehicles.
To provide customer service related to your interactions with us or to respond to your inquiry.
To verify your identity for fraud prevention purposes. We do not store this information for any other reason.
To contact you regarding an incomplete online membership form or reservation.
To contact you about a citation or claim.
To provide you with discounts, coupons, sweepstakes, offers and other information, opportunities, and services that may be of interest to you. You may receive these offers in advertising via third-party sites and media properties, including in social media. You may be able to opt-out of these ads by clicking on an icon in the ad or through the privacy settings in each media property.
To assist us in providing better products and services; for example, evaluating the performance of our staff, to assess the quality of product and service received and to help us improve our websites, facilities and services.
To compile statistics and analysis about our customers’ use of our websites, products and services, which statistics are only used to enable us to provide better customer service, products, features and functionality to you and other customers in the future.
To protect our rights and property.
We may combine the information that you submit to us with information related to your transactions with us, such as rental location and vehicle type. We may also combine this information with data we receive about you from third parties who assist us in processing requests, maintaining our data, and optimizing our services.

With your consent, we utilize text messaging, known as Short Message Service (SMS), to provide any of the following: time sensitive communications related to your transaction (e.g. construction delay at airport branch), extended rental opportunities, customer experience surveys, marketing promotions such as coupons, discounts, last minute specials or loyalty and rewards information. You will have the ability tocan opt-out of these communications by replying to the message as stated in the message.

We retain information we collect for commercially reasonable periods of time or in accordance with specific laws or policies. Information collected for a specified purpose will only be used for that purpose and, after a reasonable period of time, will no longer be actively stored when that purpose has been fulfilled. Inactive data may, however, continue to be used for statistical, marketing, archiving, and other analytical purposes.

How Your Information May Be Shared
We may disclose the information we collect from and about you to our subsidiaries and Licensees for the purpose of providing the transactions you have requested and (with your consent) marketing purposes. In addition to those stated within this Policy, Telematics Data from rental vehicles may be disclosed to, accessed by or used by Asia CiTy Tours, our subsidiaries, emergency service providers, others who may assist in responding to an accident, telematics service operators, or those with whom we have a legal or contractual obligation to provide such data. A list of our subsidiaries can be found here and a list of our licensees is available here. These lists are subject to change from time to time and you should periodically check the site for changes. Our affiliates and our subsidiary employees in our IT, marketing, operations and customer service divisions may use your information, as described in this Policy, including, if required by applicable law, to send you information about products and services or respond to your inquiry. To update your marketing preferences please see the Contacting Us section below.

We also may disclose your information to other third parties:

when required by law or in response to legal process;
without legal process in response to a request from law enforcement relating to a criminal investigation;
to protect our rights, privacy, safety or property, or of the public;
for administrative or technical support or other business purposes to facilitate our transactions with you (i.e. for your insurance replacement, corporate rental or through one of our partners);
to analyze our data, conduct mobile analytics services, or to maintain and improve our services (subject to confidentiality agreements as appropriate);
to permit us to pursue available remedies or limit damage that we may sustain;
to enforce the terms of any rental agreement or our websites’ terms and conditions;
to assist with the administration of frequent flyer or other rewards programs;
to process your transaction with our subsidiaries or licensee/franchisee located in the country in which you place your reservation;
if the rights of another individual might be violated and; otherwise with your consent.
Personal information may also be subject to transfer to another company in the event of a transfer, change of ownership, reorganization or assignment of all or part of Asia CiTy Tours’ businesses or assets. This will occur if the parties have entered into an agreement under which the collection, use and disclosure of the information is limited to those purposes of the business transaction, including a determination whether or not to proceed with the business transaction. You will be notified via email or prominent notice on our websites for thirty (30) days of any such change in ownership or control of your personal information.

We may disclose your personal information to third-party service providers (such as a payment processor to bill you for goods or services, an email provider to send email communications to you on our behalf, or the provider of our live chat feature in order to offer you customer service). These service providers may be located in a country different from your country of residence, such as the United States or a European Union member country. These service providers are contractually required to maintain the confidentiality and security of your information. However, your information may be accessible to authorities in accordance with applicable laws.

We may also share aggregated or de-identified information about our customers with our advertising and marketing partners, and third-party media properties, including social media sites to allow them to send targeted advertising messages on our behalf.

Testimonials
We may post customer testimonials/comments/reviews on our websites which may contain personally identifiable information. We will obtain your consent via email prior to posting the testimonial. To request the removal of your testimonial, please contact us through one of the methods listed below in the Contacting Us section.

Linked Sites
Our websites may contain links to other websites (such as those of our marketing partners or advertisers), which may have privacy policies that differ from our own. We are not responsible for the activities and practices that take place on these websites. Accordingly, we recommend that you review the privacy policy posted on any website that you may access through our website.

Data Security and Integrity
The security of the information you provide is very important to us and we try to provide secure transmission of your information. For certain transactions on certain of our websites, we may use Secured Sockets Layer (SSL) technology to secure the transfer of information. While we strive to protect your personal information, we cannot guarantee the security of any data transmission over the Internet. Once we receive your information, we take steps that we believe are reasonably appropriate to protect it, from loss, misuse, unauthorized access, disclosure, alteration and destruction to ensure the data’s integrity. We use a combination of technological, physical, administrative and organizational controls as well as non-disclosure or confidentiality agreements as we deem appropriate to protect your data.

If you have a user name and password for any of the features on our websites, you have the responsibility of keeping your password secret. You should not reveal your password to anyone. We will not ask you in an unsolicited telephone call or email for your password. In addition, you should take reasonable precautions when using a computer that is not your own or in a public setting.

Global Data Transfers and Processing
We will use your information in the country in which your service and transaction occurs. Please be aware that, unless prohibited by law, your use or continued use of our websites and mobile applications signifies your express consent that information may be transferred to or stored on servers and processed outside the country of your residence, including any of the countries where we do business. Please also be aware that the privacy laws of the United States or other countries where information may be stored may not be as comprehensive or offer as much protection as the laws of other countries including your country of residence. You may request us not to make such transfers, but if you do, we may not be able to provide some or all of our products or services to you.

Asia CiTy Tours and its wholly owned subsidiaries participate in and have certified their compliance with the EU-U.S. Privacy Shield Framework and the Swiss – U.S. Privacy Shield Framework. Asia CiTy Tours is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List.

Asia CiTy Tours is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Asia CiTy Tours complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Asia CiTy Tours is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Asia CiTy Tours may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request, or in Canada, you may contact the Privacy Commissioner of Canada by visiting https://www.priv.gc.ca/cu-cn/index_e.asp or at Office of the Privacy Commissioner of Canada, 30 Victoria Street, Gatineau, Quebec, K1A 1H3.

Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

To view the digital properties that comply with Privacy Shield, please click here.

When transferring personal data to countries outside the European Economic Area, we comply with European Union law by using standard contract clauses approved by the European Commission, or by adopting other means to ensure that adequate safeguards are applied, or by obtaining your consent.

Changes to this Policy
We may update this privacy policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the email address specified in your account) or by means of a notice on this site, or as otherwise may be required by law, prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contacting Us
The accuracy and completeness of the information we collect is very important to us and we make efforts to ensure that the information we have is accurate and up-to-date. In addition to the options provided to you in this Policy, if you wish to opt-out of direct marketing or review, amend, correct, or update personally identifiable information we have collected about you contact us using the information provided below. For email marketing please use the unsubscribe link located at the footer of each email.

For certain countries, you may also have rights to object to some processing of personal data or to have your personal data removed. You may contact us via email at privacy@asiacitytours.com, and we will attend to your request and make any necessary revisions. If you prefer, country specific contact information is listed below. We will respond to your request within 30 days, unless a shorter period is required. If that is the case, local legal requirements would apply. We reserve the right not to allow access to your information if we believe in good faith that such disclosure is prohibited by law or if the rights of another individual might be violated.

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